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Significance and basic problems of the international tax law. Basics of the international tax law Principles of the international tax law. Scope of the tax obligation (personal, objective scope - unlimited and limited tax obligation). International double taxation. Definition. Significance. Kinds of international double taxation. Means of avoidance of international double taxation. Models of the conventions for the avoidance of the international double taxation. Legal status of the double taxation conventions. Interpretation of the double taxation conventions. Methods of the avoidance of the international double taxation. Structure of the double taxation conventions by the articles . Internationally organized tax evasion and avoidance. Kinds of internationally organized tax evasion and avoidance. Off-shore centres. Transfer pricing. Treaty shopping. Thin capitalisation. Countermeasures. International co-operation of tax administrations. Other issues of international tax law. E-commerce. Attribution of profits to the permanent establishment. Triangular cases. Tax treatment of partnerships. Tax treatment of financial instruments. Harmful tax competition.

Cognitive Skills:

Knowledge and understanding

After successfully completing the course, students will be able to:

- define basic categories of international tax law in the context of modern legal approaches;

- critically evaluate and recognise basic factors of the occurrence of international tax law relations;

Significance and basic problems of the international tax law. Basics of the international tax law Principles of the international tax law. Scope of the tax obligation (personal, objective scope - unlimited and limited tax obligation). International double taxation. Definition. Significance. Kinds of international double taxation. Means of avoidance of international double taxation. Models of the conventions for the avoidance of the international double taxation. Legal status of the double taxation conventions. Interpretation of the double taxation conventions. Methods of the avoidance of the international double taxation. Structure of the double taxation conventions by the articles . Internationally organized tax evasion and avoidance. Kinds of internationally organized tax evasion and avoidance. Off-shore centres. Transfer pricing. Treaty shopping. Thin capitalisation. Countermeasures. International co-operation of tax administrations. Other issues of international tax law. E-commerce. Attribution of profits to the permanent establishment. Triangular cases. Tax treatment of partnerships. Tax treatment of financial instruments. Harmful tax competition.